UPDATE ON US BWM REQUIREMENTS TECHNICAL WORKSHOP May 22, 2015 UPDATE ON US BWM REQUIREMENTS JOSEPH ANGELO DEPUTY MANAGING DIRECTOR

Ballast Water Management – USCG Final Regulations issued March 23, 2012 BWM plan and recordkeeping (same as IMO) BWM discharge standard (same as IMO), review in 4 yrs Schedule for installation of BWMS similar to IMO, BUT NO intent to align schedule with Resolution A.1088 BWMS not required if no discharge of ballast water into US waters (12 miles) Acceptance of “Alternative” (AMS) BWMS for 5 years All ships must eventually install CG approved BWMS Ships may request an extension to compliance date for installation of a USCG approved BWMS

Ballast Water Management – USCG INTERTANKO Assisting Members with USCG regulations Implementation Schedule Decision Tree …

USCG Ballast Water Decision Tree

Ballast Water Management – USCG US Coast Guard INTERTANKO assisting Members Implementation Schedule Decision Tree Model Extension Request (MER) Letter

Ballast Water Management – USCG US Coast Guard – Extension requests January 1, 2016 extension date given to ships whose drydocking was scheduled for 2014 January 1, 2017 extension date given to ships whose drydocking was scheduled for 2015 Extensions for ships with drydockings in 2016 being considered Availability of USCG approved BWMS will be a factor in determining the length of time for future extensions INTERTANKO has developed Model Extension Request (MER) letter for members wishing to request extension

Ballast Water Management – USCG US Coast Guard – APPROVED BWM Systems CG has advised that 17 BWMS manufacturers have submitted “Letter of Intent” to pursue USCG approval (54 AMS accepted by USCG) For proprietary reasons, USCG cannot tell who those BWMS manufacturers are INTERTANKO has contacted BWMS manufacturers to determine which of them have submitted “Letter of Intent” (results on INTERTANKO web site) Only after the testing is completed and the results have been evaluated, will a BWMS manufacturer then submit an application to the USCG for approval of their BWMS

Ballast Water Management – USCG NK 03 Optimarine – OBS EX (UV) Coldharbour Marine Oceansaver Mk II Erma First BWTS Wartsila – Aquarius EC RWO – Cleanballast Severn Trent – Balpure Hyde Guardian (UV) DESMI – Ray Clean (UV) Techcross Electrocleen Samsung – Purimar Alfa Laval – Pureballast (UV) Trojan Marinex (UV) Evoqua – SeaCure BWTS ?? NEI – Venturi Oxygen Stripping

Ballast Water Management – USCG US Coast Guard – APPROVED BWM Systems USCG has received three applications for BWMS type approval (all three make use of UV treatment) UV BWMS need further USCG “validation” of methodology for biological efficacy CG indicates that they expect to have a USCG approved BWMS “sometime in 2015” CG indicates they will be “realistic” in requiring when a ship calling at US ports must have a CG approved BWM system installed

Ballast Water Management Shipowner dilemma!! US is not party to IMO BWM treaty. USCG regs: Allow use of Alternate Management System (AMS) for five years After five years, require installation of USCG approved BWMS Currently no BWMS is USCG approved Ship operator must decide to either install AMS (and hope it gets USCG approval!) OR request an extension and hope there is a CG approved BWMS available for installation on their ship prior to the required installation date under the IMO Convention.  

Ballast Water Management If I owned a tanker, I would – Conduct preparatory work to determine: a. which type of BWMS is best for my ship b. there is proper space to install the BWMS I want on my ship Request extension from US Coast Guard Once I know when IMO BWM convention will enter into force, request the issuance of new MARPOL Annex 1 IOPP Certificate When available, purchase USCG approved BWMS that is best for my ship  

Ballast Water Management – USEPA EPA Vessel General Permit issued December 19, 2013 To a large extent EPA VGP requirements are the same as USCG (discharge standard, compliance schedule, etc.) Approval of BWMS is not required BWMS monitoring required (functionality, equipment calibration, effluent, biocides) New ship (keel laid after December 1, 2013) is required to install a BWMS to comply with the VGP, i.e. no acceptance of USCG extension provision in the VGP EPA /USCG MoU – EPA Enforcement Policy, 27 Dec 2013 Vessel with USCG extension is non-compliant (if discharges in US waters – 3 miles), but EPA regards as a low-enforcement priority, provided all other regs are met

Ballast Water Management – USEPA Potential issue with EPA Enforcement Policy?? Charter party agreements require tanker to be in compliance with all applicable laws and regulations Tanker that receives CG extension would be in compliance with CG requirements Tanker that has CG extension and discharges ballast water within US waters (3 miles) would be in violation of EPA Vessel General Permit Would this violate charter party agreements??? Thus far, not aware of any comments from oil majors or charterers on this issue

THANK YOU! COMMENT: the +3 are BWMS with model variations, so there are 3 within the 13 BWMS approved that are simply variations of the approved BWMS, e.g. BWMS Mark 1 and BWMS Mark 2.